METLIFE Group Life (INCLUDING FLEXIBLE BENEFITS) Technical Guide



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METLIFE Group Life (INCLUDING FLEXIBLE BENEFITS) Technical Guide 1

MetLife Group Life Policies Technical Guide MetLife has a range of policies aimed to meet your life cover needs in respect of your employees and partners (equity or employed). These are: MetLife Registered Group Life MetLife Excepted Group Life MetLife Single Life Relevant Life This technical guide is effective for: new MetLife Group Life policies without Flexible Benefits first quoted on or after 23rd February 2015, unless agreed otherwise by MetLife; new MetLife Group Life policies with Flexible Benefits first quoted on or after 1st June 2015, unless agreed otherwise by MetLife; and existing MetLife Group Life policies without Flexible Benefits with a rate guarantee period review date on or after 1st April 2015, unless agreed otherwise by MetLife. What is the technical guide? The technical guide is aimed at employers and is a guide to the features, benefits (including Flexible Benefits), risks and limitations of the range of MetLife Group Life policies, including how the policies work and how you can claim. It is an important document that relates to the quotation that has been issued with it. If there is anything you are not sure about, you can ask your financial intermediary or MetLife (as appropriate). We recommend you keep this document in a safe place in case you need to refer to it in the future. The technical guide does not specify the standard contractual terms, which can be found in the MetLife Group Life policy terms and conditions specific to the policy(ies) you have with MetLife. This technical guide has been produced based on the best practice standard format recommended by the Group Risk Development Group ( GRiD ) and the Association of British Insurers ( ABI ). About MetLife MetLife Group Life policies are provided and underwritten by MetLife Europe Limited, UK branch, which trades as MetLife. Further information about MetLife can be found on the website www.metlife.co.uk. MetLife do not offer advice in respect of these policies. Please contact your financial intermediary should you have any questions in relation to the level and type of cover you should choose. 2

Contents Aims, Commitments and Risks 4 How does a MetLife Group Life policy work? 10 Your questions answered about the MetLife Group Life policy 12 1 How do you determine what segment size applies to a policy? 12 2 What factors should be considered when deciding what benefits to provide? 12 2.1 Who can be covered? 12 2.2 What are your actively at work requirements? 13 2.3 What types of cover are available? 21 2.4 Are there any extensions of cover available under the policy? 21 3 Setting up the policy 23 3.1 Quotation process for MetLife Group Life cover without Flexible Benefits 23 3.2 Quotation process for MetLife Group Life cover with Flexible Benefits 23 3.3 Requirements to set up the policy 24 3.4 How cover is granted under the policy 24 3.5 Temporary cover 26 3.6 Benefit increases 27 4 What premiums are charged for the cover? 27 4.1 How will premiums be calculated? 28 4.2 Will there be any extra premiums payable? 29 4.3 What commission is included within the premium? 29 4.4 Is there a discount for good claims experience? 29 5 How does the policy accounting work? 29 5.1 What information is required for accounting purposes? 29 5.2 How are accounts adjusted for members who join, leave or have benefit changes during the year? 30 5.3 If the policy is discontinued mid-year will premium paid in advance be lost? 31 5.4 What happens at the end of the rate guarantee period? 31 6 What is covered? 32 7 What is not covered (exclusions)? 32 8 How can a claim be made? 32 8.1 Notification 32 8.2 Claim payments 33 9 When will cover stop? 33 9.1 When will cover stop for a member? 33 9.2 Terminating the policy 34 10 Can cover be provided for employees or partners who are not in the UK? 34 11 How are schemes taxed? 35 12 Continuation option 35 13 Law 36 14 Further information 36 3

Aims, Commitments and Risks Aims MetLife s Group Life policies aim to provide a lump sum when an insured member dies. Separate policies are issued when the employer takes out cover for a registered pension scheme and / or an excepted group life scheme, and / or takes out a single life relevant life policy. Flexible Benefits - MetLife Group Life policies can insure life cover provided by an employer s Flexible Benefits Scheme, whereby employees can increase or reduce their life cover during benefit selection periods and following specified lifestyle events. How MetLife Group Life Flexible Benefits operate is covered within this technical guide. In order for Group Life Flexible Benefits to be provided, there must be a minimum of 250 members to be covered under the MetLife Group Life policy(ies). Where Flexible Benefits are required, an Implementation Manager will be appointed by MetLife to ensure operational and administrative functionality is in place between MetLife and the employer s Flexible Benefits Scheme platform ready for implementation. We will issue 1 quotation, and it will include the basis of the MetLife Group Life Flexible Benefits cover. Once cover is confirmed and the policy benefit from the commencement date is known, MetLife will issue policies to match the life cover needs of the employer s Flexible Benefits Scheme. The number (i.e. 1 or more) and type (i.e. MetLife Registered Group Life, MetLife Excepted Group Life and / or MetLife Single Life Relevant Life policies) will depend on these needs. Linked policies where separate policies are issued, it can be possible to link policies for the purpose of the unit rate of premium, free cover limit and / or catastrophic event limit. There are underwriting requirements that must be met for this to be agreed by MetLife. In the event this is required for your MetLife Group Life policies, please let us know when you request a quotation from us. We will initially issue 1 quotation, and it will include a statement setting out the basis of the linking of the policies. In the event one of the linked policies is terminated, this may result in a re-rate and / or re-underwrite of the remaining policy or policies. In respect of a MetLife Single Life Relevant Life policy, this must be linked to a MetLife Registered Group Life policy and / or a MetLife Excepted Group Life policy in order that MetLife can issue a quotation and go on-risk. In these circumstances, the cost of the MetLife Single Life Relevant Life policy will be based on the unit rate of the linked policy. In the event the linked policy is terminated, the MetLife Single Life Relevant Life policy will automatically terminate. Policyholder s and / or Trustee s Commitments To disclose all material facts relating to the risk to be insured and provide all the information MetLife asks for when applying for a policy, at review dates, guarantee expiry dates or in support of a claim and to advise MetLife if these details change. Material facts are those which would affect an underwriter s assessment of the risk. This duty of disclosure is important. If these facts are not disclosed and / or all information is not provided, cover may be void and the payment of claims may be affected (i.e. claims may be reduced or declined). To provide accurate membership data when applying for the policy, at review dates and at guarantee expiry dates. Membership data is required at least once in every 12 month period of cover. Where Flexible Benefits are provided, changes to membership data may be required more frequently. To pay regular premiums fully, as and when they are due. To abide by the policy terms and conditions. As soon as you are aware and as soon as is reasonably practicable, to notify MetLife: a. of any members whose benefit is above the free cover limit; b. of any potential claims; c. of any discretionary entrants; 4

d. of any change in business location or business nature of the employer or group of members covered under the policy; e. of any change in the employment status or partnership status of any members; f. if the policyholder intends to amend the eligibility criteria of the policy; g. if there is a 30% or more change in the total number of members covered and / or the total cover since the later of the commencement date and the last review date; h. where Flexible Benefits are not provided, if the total number of members falls below 3 or increases to 3 or more; and if Flexible Benefits are provided, if the total number of members falls below 250; i. of any change in the nature of the employer s business that exposes members to any change in accident risk or exposure to hazardous substances; j. if the employer acquires another company or business and wishes to cover the employees and / or partners of the new company or business in the existing scheme; Risks There are a number of reasons for which MetLife may terminate a policy, at which point cover will cease. These are detailed in the relevant policy terms and conditions. Valid claims that accrued when cover existed will be paid even if the policy has been terminated, provided premiums have been paid for that period of cover. The rate used to calculate premiums is guaranteed for a period agreed in writing by MetLife, and is then reviewed at the guarantee expiry date. The rate may change at any time if: a. there is a 30% or more change in the total number of members covered and / or the total cover since the commencement date or the last review date, whichever is later; b. there is a change to the eligibility conditions or benefit basis; c. if any new regulation (or change in legislation or HMRC practice) comes into force which affects the way that premiums and / or policy benefits are treated; k. if the employer disposes of a company or business and wishes to remove cover for the employees and / or partners of that company or business; and l. if the policyholder wishes to terminate the policy. To pass on the appropriate benefits paid under the policy to the member s appropriate beneficiaries. In respect of a MetLife Registered Group Life policy, to maintain a scheme registered with Her Majesty s Revenue and Customs ( HMRC ) and to set up a trustee bank account in order to receive claim payments. 5

d. there is a change in the business location or business nature of the employer or group of members covered under the policy; e. there is the inclusion of new members to be covered under the policy following the purchase of a new company, the inclusion of a new subsidiary / business division, or a new category of employees and / or partners; or f. there is the removal of members to no longer be covered under the policy as a result of the disposal of a company, the removal of a subsidiary / business division, or removal of a category of employees and / or partners. MetLife reserves the right to change the unit rate of premium and / or age rate of premium, or single premium, and / or the policy terms and conditions of each policy at each guarantee expiry date or at any time for particular events as detailed in the policy terms and conditions. MetLife reserves the right to change the premiums if there is a change in the law or regulations affecting the premiums. Any delays in providing the information MetLife requests, or if the information is incomplete or inaccurate, may result in declined claims or delays in claim payments. In addition, the claim amount may be reduced, premiums may be increased, and employees or partners may not be covered. MetLife also reserves the right to terminate the policy and if due, refund any premiums already paid. Any policy specific exclusions in respect of a policy will be shown on the quotation and / or the policy schedule. Special terms may also apply to individual members and these will be confirmed in writing. From 1 October 2006, the Employment Equality (Age) Regulations 2006 made it unlawful for an employer to discriminate against an employee or partner based on their age. The policyholder may need to take legal advice to understand any areas where the benefits provided by their insurance policy do not meet the requirements of these regulations. Unless otherwise specified, quotations are guaranteed for 90 calendar days. MetLife can terminate the policy, amend the terms or issue a new policy in the event of any war or act of war which MetLife believes could adversely affect the policy or its operation. MetLife will only pay the policy benefit if a claim has been made within a period of 24 months commencing on the date the policyholder / trustee could reasonably have known of the member s death. The policyholder and / or trustee should be aware of any members whose registered benefits may have lifetime allowance protection. Employers need to take legal advice to understand any possible impact on a member s protected benefits before taking out cover with MetLife. The policyholder and / or trustee should be aware of any members who are in receipt of a pension and wish to be eligible for lump sum death benefits. Employers may need to take legal advice to understand any possible impact on a member s benefits before taking out cover with MetLife. If a catastrophic event, as defined by the policy, occurs, an overall limit may apply on the total claim amount paid. If MetLife has already paid benefits to the catastrophic event limit which is set out in the policy schedule for 1 catastrophic event, then no further benefits will be paid out for that event. Auto-enrolment What is auto-enrolment? The Pensions Act 2008 requires all employers to automatically enrol their workers into a qualifying pension scheme (if they re not already in one), and then contribute to that scheme. Each employer is given a specific staging date on which to do this. Workers can opt out of auto-enrolment if they wish (within the opt-out period to receive a refund of pension payments already made), but they will be automatically enrolled back into the scheme every 3 years. 6

If a worker has enhanced or fixed protection, this is lost if they join a pension scheme and accrue additional pension benefits. They will be automatically enrolled into an employer s pension scheme, and so will need to opt-out within the one month opt-out period to avoid losing this protection. Why can auto-enrolment affect group life cover? Auto-enrolment can affect group life cover if eligibility for the group life cover is linked to pension scheme membership. For example, workers could all be on a base level of group life cover of 2 x salary, but if they join the pension scheme, this increases to 4 x salary. Alternatively, workers may not be entitled to any group life cover unless they join the pension scheme. If eligibility for group life cover is not linked to pension scheme membership, then the MetLife Group Life policy is not affected by auto-enrolment and this section is not relevant. New business and review quotations not so far affected by autoenrolment When issuing a quotation, unless MetLife have already been notified that the policy will be affected by auto-enrolment in the coming policy year and cover is required for auto-enrolled employees, MetLife assumes no cover or increase in benefits will be provided under the policy as a result of auto-enrolling eligible employees and / or eligible partners into the pension scheme. This assumption is specified on the quotation. If this assumption is incorrect, MetLife must be notified, and MetLife reserve the right to change their rate and / or acceptance terms. Main auto-enrolment principle for MetLife Group Life policies As long as the auto-enrolled worker is actively at work the day before their auto-enrolment date, and they do not opt out of the pension scheme, then they are automatically covered under the MetLife Group Life policy. If they are not actively at work, cover as a result of auto-enrolment is subject to satisfactory evidence of health. In the event of a new employee being automatically enrolled into the pension scheme on their joining date, they would be joining the pension scheme within 12 months of their first opportunity of doing so, and so would be classed as a standard new entrant for the purpose of a MetLife Group Life policy linked to pension scheme membership. Unlike existing employees who were auto-enrolled, any actively at work requirements for new entrants apply as at the date of their joining, not the day before their joining date. If a worker opts out of the pension scheme on first auto-enrolment, but then chooses not to opt out on a subsequent re-auto-enrolment, they are treated as a discretionary entrant and cover is subject to satisfactory evidence of health. The actively at work requirement can be waived on a case by case basis at the absolute discretion of MetLife. Registered Group Life policies Registered group life policies insure registered group life schemes. A registered group life scheme is a scheme that is registered with HMRC as a registered occupational pension scheme under section 153 of chapter 2 of the Finance Act 2004 (as amended, superseded or replaced) and which provides benefits on the death of insured members of the scheme. In respect of policies that have not been assigned to the MetLife Master Trust, employers or trustees must set up a trust by executing a trust deed before registering the scheme with HMRC. MetLife can provide specimen trust deed and scheme rules to assist with this. If HMRC regards the scheme as no longer being registered, then MetLife will automatically terminate the policy at that date. MetLife Master Trust MetLife offer employers access to the MetLife Master Trust, a registered pension scheme (PSTR 00797470RC). An employer assigns the policy benefit to the trust by way of a Deed of Participation, and in the event of a claim, MetLife 7

pay the policy benefit to the trustee, Castlewood Trust Corporation Limited. As trustee they have discretionary powers to pay the benefit to the appropriate beneficiaries. Castlewood also act as scheme administrator and are responsible for HMRC reporting in respect of the scheme. Important points to note: In the event of the MetLife policy being terminated, this automatically removes the policy from the MetLife Master Trust. Only policy benefits payable from a MetLife policy can be assigned to the MetLife Master Trust. The MetLife Master Trust only provides for lump sum death benefits. It does not provide for dependant s pension benefits or retirement benefits. MetLife Bereavement and Probate Service MetLife offer employers access to the MetLife Bereavement and Probate Service for their insured members and their household families. The service offers telephone and face to face bereavement counselling, and telephone legal advice in respect of probate issues. This emotional and practical support is provided at no extra charge to the insured members, their families or the policyholder. Lifetime allowance protection The lifetime allowance is the maximum amount of lump sum and / or pension that benefits from tax relief (a combination of exemptions and deductions on income and expenditure to recognise taxable income) for a member receiving benefit from their registered pension schemes. The current standard lifetime allowance for the tax year 2015/2016 is 1.25m, and this will reduce to 1m for the tax year 2016/2017. This will change in future tax years. Benefit payable in excess of the lifetime allowance may be subject to a tax charge. More details can be found at: www.hmrc.gov.uk. Since the introduction of the lifetime allowance on 6th April 2006, HMRC have introduced various forms of protection as the lifetime allowance has changed: primary protection, enhanced protection, fixed protection, fixed protection 2014 and individual protection 2014. The protection rules are complicated, and the ways in which protection can be lost differ depending on the type of registered pension scheme providing retirement income and lump sum benefits. An individual may wish to seek independent financial advice before making decisions in respect of their registered benefits. Excepted Group Life policies Excepted Group Life policies are exempt from the chargeable event regime. An excepted group life policy is defined in section 480(3) of the Income Tax (Trading and Other Income) Act 2005, and it must meet certain conditions in order for it to be considered an excepted group life policy, and as such exempt from chargeable event rules. What are the conditions an excepted group life policy must meet? 1. Minimum of 2 members There must be a minimum of 2 members. MetLife require a minimum of 2 members in respect of policies with Flexible Benefits or a minimum of 3 members in respect of policies without Flexible Benefits in order to be able to put a MetLife Excepted Group Life policy on risk. If MetLife have agreed to link the policy with another MetLife Registered Group Life policy, MetLife Excepted Group Life policy and / or MetLife Single Life Relevant Life policy, a higher minimum number of members may be required. 8

2. Age restriction of 75 The maximum age at which death benefit is payable must be no more than 75. 3. Death exclusion clauses Whilst there is a general condition that a benefit must be payable on each death of a member insured under the policy, an exception is allowed where the policy contains exclusion for death in certain circumstances. This exclusion must apply to all members covered under the policy. Individual exclusions are not permitted. 4. Same benefit calculation method The same method must be used for calculating the benefits payable. For example, benefit calculation can be a multiple of salary, and this multiple must be the same for all members covered by the policy. Basing benefits on 2 x salary for one category of members, and 4 x salary for another category, is not permitted. 5. Lump sum death benefit only Benefit must be a capitalised lump sum only. Dependant s pension benefits are not permitted under an excepted group life scheme. 6. No surrender value There must be no surrender value available under the policy. Only a refund of unused premiums is permitted. 7. No other benefits payable Only death benefits are payable under the policy. 9. No receipt of each other s benefit Lump sum benefits are not payable to anyone insured in the scheme unless they could receive the benefit if they were not insured in the scheme as a financial dependant of the deceased. 10. Not for the avoidance of tax The policy must not be taken out for the main purpose of avoiding tax. Single Life Relevant Life policies A single life relevant life policy is a policy which satisfies the criteria for a relevant life policy in respect of the death of a single individual as defined in subsection 393B(4) of the Income Tax (Earnings and Pensions) Act 2003 (as amended, superseded or replaced). A single life relevant life policy can only be taken out with MetLife when it is linked to a MetLife Registered Group Life policy and / or MetLife Excepted Group Life policy, satisfying the minimum number of members requirements MetLife has set. The cost of the MetLife Single Life Relevant Life policy will be based on the unit rate of premium and / or age rate of premium (as appropriate) applicable to the linked policy. In the event the linked policy is terminated by the employer or MetLife, the MetLife Single Life Relevant Life policy automatically terminates at the same time. In the event of a valid claim under the policy being paid, the policy automatically terminates on the death of the single insured member. 8. Benefits payable to entitled individual or trustee The benefits payable under the policy must either be paid to an individual entitled to the benefits, or a trustee for payment to individuals. 9

How does a MetLife Group Life Policy work? Where Flexible Benefits are not provided, the policyholder chooses the benefit structure (a defined lump sum benefit payable in the event of the death of an insured member) and eligibility conditions for the MetLife Group Life policy which is subject to MetLife s acceptance. Where Flexible Benefits are provided, the policyholder chooses the default policy benefit (a defined lump sum benefit payable in the event of the death of an insured member) which can be changed by individual members during a benefit selection period and on specified lifestyle events, subject to the minimum and maximum policy benefit and permitted benefit steps, and eligibility conditions for the MetLife Group Life policy which is subject to MetLife s acceptance. MetLife provides cover whilst payment of premium continues no matter how many claims are made subject to the limits set out in the policy schedule including those at member level. MetLife will continue to admit and pay claims, subject to the policy terms and conditions, where the death of a member occurs whilst premiums are still being paid, assuming the policy has not been formally terminated. The premiums payable in respect of group life policies are usually treated for tax purposes as a trading expense. Premiums are not normally treated as a benefit in kind for employees. MetLife will not accept premium payments from anyone other than the employer or employers listed in the policy schedule (as opposed to the employees or partners). The premium payment methods available remain unchanged for partners, even if each individual partner pays for their own cover. Where each pays for their own cover, partial premium payments from multiple partners covered under one policy are not accepted. Payment must be a single payment from the employer. A partner is an equity partner of a partnership or an individual (member) listed in the incorporation document of a Limited Liability Partnership. MetLife only provides cover from the commencement date onwards, i.e. from the date MetLife agrees to take on the risk going forward. MetLife does not provide cover before that date. Therefore, any death that occurred before the commencement date is not covered by a MetLife Group Life policy. The guarantee expiry date stated in the policy schedule applies to both the premium rate and the terms and conditions that apply to the policy. At each guarantee expiry date, the unit rate of premium and / or age rate of premium, or single premium, and the policy terms and conditions may be changed. For a MetLife Registered Group Life policy, different levels and / or types of benefits can be provided for different categories of employees and partners. Where different benefit bases are required for a MetLife Excepted Group Life policy, 1 policy will be issued for each benefit basis. 10

The policyholder must, as soon as reasonably practicable, provide MetLife with information required for assessing a claim. On request, a specimen trust deed and scheme rules can be provided by MetLife. This service is provided at no additional cost to the trustee. The employer should take legal advice to ensure that the trust is suitable for their needs. It is the employer s and / or trustees responsibility to ensure that such documentation is fully and accurately completed and executed correctly. Where relevant, MetLife pays the benefit to the trustees, who, under discretionary powers, pay the benefit, usually, to the deceased s legal personal representatives. Claim payment will be made by direct credit where possible, otherwise payment will be by cheque made payable to the trustees or policyholder. Lump sum benefits paid by trustees do not normally form part of the deceased member s estate. Therefore, they are normally free of inheritance tax and can be paid immediately. In addition in respect of MetLife Registered Group Life policies: A pension scheme (which may only provide death benefits) must be registered with HMRC and the trustee will be the scheme administrator unless they have appointed someone else who has agreed to carry out this role. The trustee must set up a trustees bank account to receive any claim payment made by MetLife. 11

Your questions answered about the MetLife group life policy 1. How do you determine what segment size applies to a policy? There are a number of aspects of MetLife s Group Life policies where the number of eligible employees and / or eligible partners to be covered under the policy, or the number of insured members covered under the policy, determine what parts of the policy terms and conditions apply to the policy. In respect of cover from the commencement date of the policy, MetLife use the number of eligible employees and / or eligible partners as at the commencement date of the policy. This means if the number of eligible employees and / or eligible partners increases or decreases between a quotation date and the commencement date, MetLife will take the number as of the commencement date, even if this results in a change in the actively at work requirements for cover under the policy. In respect of the policy once it is on risk, MetLife uses the number of insured members as at the later of the last guarantee expiry date and the commencement date of the policy. This means if the number of insured members increases or decreases after the last guarantee expiry date or commencement date, but before the next guarantee expiry date, this does not result in a change of requirements under the policy. 2. What factors should be considered in deciding what benefits to provide? You should consider: The contractual benefits you have offered your employees and partners (which may or may not include Flexible Benefits). How important group life benefits are to the benefit package you offer your employees and partners. Whether the benefit amount or the earnings used to calculate the benefit should be restricted to a maximum amount e.g. the benefit amount can be limited to the Lifetime Allowance or the earnings can be limited to a notional earnings cap. Whether you want to give the same benefits to all scheme members, or different levels of benefits to different categories of members. 2.1 Who can be covered? An employee or partner will become a member when the eligibility and actively at work conditions set out in the policy terms and conditions and policy schedule are satisfied and the member is joining the scheme at their first opportunity (unless eligibility is linked to pension scheme membership section 2.2.1). These conditions also apply to increases in cover for existing members. The eligibility conditions will need to be defined by the employer and will include for each category: a. Minimum and maximum entry ages; b. Minimum service qualification periods; c. Termination ages; d. The date that new entrants can join the policy; e. When existing members benefit will increase; and f. Whether cover is dependent on membership of a pension scheme. If so, then it is the pension scheme s current eligibility terms, which must be specified and the take up rate should also be confirmed. Membership must be open to all employees and partners within a defined category or categories. 12

The eligibility conditions must be the same for all members within a defined category. The benefits provided by the policy should comply with the Employment Equality (Age) Regulations 2006 and the Employment Equality (Repeal of Retirement Age Provisions) Regulations 2011, as well as any other relevant laws on discrimination. An employer should consider these regulations when setting the eligibility conditions so that they can understand any areas where the benefits provided by the employer scheme are not consistent with the benefits provided by the policy. Members that satisfy the eligibility conditions can be permanent full-time and part-time employees, partners and temporary employees who are contracted to work for a period of one month or more for any employer covered under the policy. 2.1.1 Removal of the default retirement age Group risk insured benefits provided by employers for their employees and / or partners are exempt from the principle of equal treatment on the grounds of age. Employers can stop providing or offering insured benefits to their employees and / or partners who are aged 65 or over. The age at which group risk insured benefits can be withdrawn increases in line with the state pension age ( SPA ). A person s SPA is governed by their date of birth. If a member s SPA exceeds the termination age of a MetLife Group Life policy, cover will continue to be granted up to their SPA. However, no cover will be granted beyond the age of 75. 2.2 What are your actively at work requirements? The relevant Actively at Work conditions set out below will need to be satisfied before a member is considered for cover. Definition of Actively at Work Being actively at work means that an employee or partner has not received medical advice to refrain from work and is actively engaged in or is otherwise following their normal occupation i.e. the employee or partner is mentally and physically capable of working their normal contracted number of hours, either at their usual place of business or at the location to which business requires them to travel. Absence from work does not include holidays, maternity, paternity and adoption leave, or any other authorised leave approved by MetLife. Definition of Strict Actively at Work Applying a strict actively at work definition means that an employer or partner is actively at work (as defined above) and has not failed to be actively at work for 5 or more working days in the last 12 calendar months. The 5 days do not need to be consecutive. 13

2.2.1 Actively at work requirements for eligible employees, eligible partners and / or insured members who are below the termination age of the policy Scenario / policy size Fewer than 20 members Between 20 and 49 members 50 or more members without Flexible Benefits 250 or more members with Flexible Benefits All eligible employees/ partners at the commencement date of the policy In order to be covered under the policy from the commencement date, members must be actively at work on the day before the commencement date and a completed and signed actively at work declaration form must be provided within 30 days of the commencement date of the policy. Cover for any members who are not actively at work on the day before the commencement date is subject to satisfactory evidence of health. In order to be covered under the policy from the commencement date, members must be actively at work on the day before the commencement date. For any members who are not actively at work on the day before the commencement date, they will be covered when they have returned to work and are actively at work for at least 5 consecutive working days. A completed and signed actively at work declaration form does not need to be provided. Where a scheme is switching from a previous insurer and the benefit basis is improving for fewer than 20 members, then cover under the policy for those members is subject to the same actively at work criteria as that for policies with fewer than 20 members. All members are covered under the policy from the commencement date regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Where a scheme is switching from a previous insurer and the benefit basis is improving for: fewer than 20 members, then cover for those members is subject to the same actively at work criteria as that for policies with fewer than 20 members. A completed and signed actively at work declaration form must be provided for those members that are eligible for the improved benefits; and / or; between 20 and 49 members, then cover for those members is subject to the same actively at work criteria as that for policies with between 20 and 49 members. A completed and signed actively at work declaration does not need to be provided Policy benefit reduced or not increased during a benefit selection period immediately prior to the commencement date of the policy All members are covered under the policy from the commencement date regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Where a scheme is switching from a previous insurer and the benefit basis is improving for: fewer than 20 members, then cover for those members is subject to the same actively at work criteria as that for policies with fewer than 20 members. A completed and signed actively at work declaration must be provided for those members that are eligible for the improved benefits; and / or between 20 and 49 members, then cover for those members is subject to the same actively at work criteria as that for policies with between 20 and 49 members. A completed and signed actively at work declaration does not need to be provided. Policy benefit increased during a benefit selection period immediately prior to the commencement date of the policy In order to be covered under the policy from the commencement date in respect of the increased policy benefit, members must be actively at work on the day they choose to increase their policy benefit. For any members who are not actively at work on the day they choose to increase their policy benefit, they will be covered in respect of the increased policy benefit when they have returned to work and are actively at work for at least 1 working day. The increased policy benefit will not be provided any earlier than the commencement date. Where a scheme is switching from a previous insurer and the benefit basis is improving for: fewer than 20 members, then cover for those members is subject to the same actively at work criteria as that for policies with fewer than 20 members. A completed and signed actively at work declaration must be provided for those members that are eligible for the improved benefits; and / or between 20 and 49 members, then cover for those members is subject to the same actively at work criteria as that for policies with between 20 and 49 members. A completed and signed actively at work declaration does not need to be provided. 14

Scenario / policy size Fewer than 20 members Between 20 and 49 members 50 or more members without Flexible Benefits 250 or more members with Flexible Benefits New eligible employees/ partners joining the scheme during the term of the policy ( standard new entrants ) In order to be covered under the policy from their joining date, members must be actively at work on their joining date. Cover for any members who are not actively at work on their joining date is subject to satisfactory evidence of health. MetLife must be notified of any new entrants that are not actively at work on their joining date. A completed and signed actively at work declaration form must to be provided. In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who are not actively at work on their joining date, cover will be provided when they have returned to work and are actively at work for at least 5 consecutive working days. A completed and signed actively at work declaration form does not need to be provided. Members are covered from their joining date regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Policy benefit reduced or not increased during a benefit selection period immediately after their joining date Members are covered under the policy from their joining date regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Policy benefit increased during a benefit selection period immediately after their joining date In order to be covered under the policy for the increased policy benefit from the day their increased benefit is effective following a benefit selection period, members must be actively at work on the day they choose to increase their policy benefit. For any members who are not actively at work on the day they choose to increase their policy benefit, they will be covered in respect of the increased policy benefit when they have returned to work and are actively at work for at least 1 working day. The increased policy benefit will not be provided any earlier than the date increased benefit is to be effective following the end of a benefit selection period. A completed and signed actively at work declaration form does not need to be provided. Improvement to the benefit basis during the term of the policy including increases in termination age but excluding TUPE transfers* In order to be covered for the improved benefits from the day the benefit basis improves, members must be actively at work on the day the benefit basis improves. A completed and signed actively at work declaration form must be provided within 30 days of the improvement in benefit basis. In order to be covered for the improved benefits on the day the benefit basis improves, members must be actively at work on the day the benefit basis improves. Any members who are not actively at work on the day the benefit basis improves will not receive the improved benefits until they have returned to work and are actively at work for at least 5 working days. Members are covered for the improved benefits from the day the benefit basis improves regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Improved benefit basis as a result of a change by the employer Members are covered for the improved benefits from the day the benefit basis improves regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Where the benefit basis is improving for: fewer than 20 members, then cover for those members is subject to the same actively at work criteria as that for policies with fewer than 20 members. A completed and signed actively at work declaration must be provided for those members that are eligible for the improved benefits; and / or between 20 and 49 members, then cover for those members is subject to the same actively at work criteria as that for policies with between 20 and 49 members. A completed and signed actively at work declaration does not need to be provided. 15

Scenario / policy size Fewer than 20 members Between 20 and 49 members 50 or more members without Flexible Benefits 250 or more members with Flexible Benefits Continued Improvement to the benefit basis during the term of the policy including increases in termination age but excluding TUPE transfers* Any members who are not actively at work on the day the benefit basis improves will not receive the improved benefits until satisfactory evidence of health is provided. A completed and signed actively at work declaration form does not need to be provided. Members are covered for the improved benefits from the day the benefit basis improves regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Improved benefit basis as a result of a change by the member during a benefit selection period or following a specified lifestyle event In order to be covered for the improved benefits from either the next review date, or the day their increased benefit is effective following a lifestyle event, members must be actively at work on the day they choose to improve their benefit basis. For any members who are not actively at work on the day they choose to improve their benefit basis, they will not receive the improved benefits until they have returned to work and are actively at work for at least 1 working day. A completed and signed actively at work declaration form does not need to be provided. Staff are transferring into the employer s service by way of a TUPE transfer* In order to be covered under the policy from the day of the transfer, members must be actively at work on the day of the transfer and a completed and signed actively at work declaration must be provided within 30 days of the date of the transfer. Cover for any members who are not actively at work on the day of the transfer is subject to satisfactory evidence of health. In order to be covered under the policy from the day of the transfer, members must be actively at work on the day of the transfer. For any members who are not actively at work on the day of the transfer, they will be covered when they have returned to work and are actively at work for at least 5 consecutive working days. A completed and signed actively at work declaration form does not need to be provided. Members are covered from the day of the transfer regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Policy benefit reduced or not increased during a benefit selection period immediately following the transfer Members are covered under the policy from their transfer date regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Policy benefit increased during a benefit selection period immediately following the transfer In order to be covered under the policy for the increased policy benefit from the day the increased benefit is effective following a benefit selection period, members must be actively at work on the day they choose to increase their policy benefit. For any members who are not actively at work on the day they choose to increase their policy benefit, they will be covered in respect of the increased policy benefit when they have returned to work and are actively at work for at least 1 working day. The increased policy benefit will not be provided any earlier than the day the increased benefit is effective following the end of a benefit selection period. A completed and signed actively at work declaration form does not need to be provided. * In respect of an improvement to the benefit basis and increase in termination age, including when staff are transferred into the employer s service by way of the Transfer of Undertakings (Protection of Employment) Regulations 2006 (also known as TUPE transfer or TUPE d ), the number of individuals affected will impact which segment the change applies to. For example, if 25 individuals are TUPE d into the employer s service which has 150 members in its current workforce, the actively at work criteria that will apply will be that for the 20-49 member policy size. 16

2.2.2 Actively at work requirements for eligible employees, eligible partners and / or insured members above the termination age of the policy ( late retirement cover ) Scenario / policy size Fewer than 20 members Between 20 and 49 members 50 or more members without Flexible Benefits 250 or more members with Flexible Benefits For an existing MetLife Group Life policy where cover for an existing insured member is required beyond termination age In order to be covered under the policy from the day they reach the termination age, a member must meet MetLife s strict actively at work definition on the day they reach the termination age and a completed and signed actively at work declaration form must be provided. Cover for any members who do not meet MetLife s strict actively at work definition on the day they reach the termination age is subject to satisfactory evidence of health. In order to be covered under the policy from the termination age, members must be actively at work the day they reach the termination age. For any members who are not actively at work the day they reach the termination age, they will be covered when they have returned to work and are actively at work for at least 1 working day. A completed and signed actively at work declaration form does not need to be provided. For a scheme that is switching from another insurer and cover is required for members older than the termination age, that have been accepted for cover by the previous insurer In order to be covered under the policy from the commencement date, members must be actively at work on the day before the commencement date and a completed and signed actively at work declaration form must be provided within 30 days of the commencement date of the policy. In order to be covered under the policy from the commencement date, members must be actively at work on the day before the commencement date. For any members who are not actively at work on the day before the commencement date, they will be covered when they have returned to work and are actively at work for at least 5 consecutive working days. Members are covered under the policy from the commencement date regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Policy benefit reduced or not increased during a benefit selection period immediately prior to the commencement date of the policy All members are covered under the policy from the commencement date regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Where a scheme is switching from a previous insurer and the benefit basis is improving for: fewer than 20 members, then cover for those members is subject to the same actively at work criteria as that for policies with fewer than 20 members. A completed and signed actively at work declaration must be provided for those members that are eligible for the improved benefits; and / or between 20 and 49 members, then cover for those members is subject to the same actively at work criteria as that for policies with between 20 and 49 members. A completed and signed actively at work declaration does not need to be provided. 17

Scenario / policy size Fewer than 20 members Between 20 and 49 members 50 or more members without Flexible Benefits 250 or more members with Flexible Benefits Continued For a scheme that is switching from another insurer and cover is required for members older than the termination age, that have been accepted for cover by the previous insurer Cover for any members who are not actively at work on the day before the commencement date is subject to satisfactory evidence of health. A completed and signed actively at work declaration form does not need to be provided. Where a scheme is switching from a previous insurer and the benefit basis is improving for fewer than 20 members, then cover for those members is subject to the same actively at work criteria as that for policies with fewer than 20 members. Where a scheme is switching from a previous insurer and the benefit basis is improving for: fewer than 20 members, then cover under the policy for those members is subject to the same actively at work criteria as that for policies with fewer than 20 members. A completed and signed actively at work declaration form does not need to be provided; and / or between 20 and 49 members, then cover under the policy for those members is subject to the same actively at work criteria as that for policies with between 20 and 49 members. A completed and signed actively at work declaration form does not need to be provided. Policy benefit increased during a benefit selection period immediately prior to the commencement date of the policy In order to be covered under the policy from the commencement date in respect of the increased policy benefit, members must be actively at work on the day they choose to increase their policy benefit. For any members who are not actively at work on the day they choose to increase their policy benefit, they will be covered in respect of the increased policy benefit when they have returned to work and are actively at work for at least 1 working day. The increased policy benefit will not be provided any earlier than the commencement date. A completed and signed actively at work declaration form does not need to be provided. Where a scheme is switching from a previous insurer and the benefit basis is improving for: fewer than 20 members, then cover for those members is subject to the same actively at work criteria as that for policies iwth fewer than 20 members. A completed and signed actively at work declaration must be provided for those members that are eligible for the improved benefits; and / or between 20 and 49 members, then cover for those members is subject to the same actively at work criteria as that for policies with between 20 and 49 members. A completed and signed actively at work declaration does not need to be provided. For an existing MetLife Group Life policy where cover is required for a new entrant who is older than the termination age Member is treated as a discretionary entrant and cover is subject to satisfactory evidence of health. MetLife must be notified of such members. In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who are not actively at work on their joining date, they will be covered when they have returned to work and are actively at work for at least 5 consecutive working days. A completed and signed actively at work declaration form does not need to be provided. In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who are not actively at work on their joining date, they will be covered when they have returned to work and are actively at work for at least 1 working day. A completed and signed actively at work declaration form does not need to be provided. Policy benefit reduced or not increased during a benefit selection period immediately prior to the commencement date of the policy In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who are not actively at work on their joining date, they will be covered when they have returned to work and are actively at work for at least 1 working day. A completed and signed actively at work declaration form does not need to be provided. Policy benefit increased during a benefit selection period immediately prior to the commencement date of the policy In order to be covered under the policy for the increased policy benefit from the day the increased benefit is effective following a benefit selection period, members must be actively at work on the day they choose to increase their policy benefit. For any members who are not actively at work on the day they choose to increase their policy benefit, they will be covered in respect of the increased policy benefit when they have returned to work and are actively at work for at least 1 working day. The increased policy benefit will not be provided any earlier than the day the increased benefit is effective following the end of a benefit selection period. A completed and signed actively at work declaration form does not need to be provided. 18

2.2.3 Actively at work requirements where eligibility is dependent on membership of a pension scheme (not related to auto-enrolment) Actively at work requirement Scenario Fewer than 20 members Between 20 and 49 members 50 or more members without Flexible Benefits 250 or more members with Flexible Benefits Member joins the pension scheme within 12 months of their first opportunity to do so In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who are not actively at work on their joining date, cover is subject to satisfactory evidence of health. In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who are not actively at work on their joining date, they will be covered once they have returned to work and are actively at work for at least 5 consecutive working days. Members who are covered under the policy from their joining date regardless of whether they are actively at work or not. A completed and signed actively at work declaration form does not need to be provided. Policy benefit reduced or not increased during a benefit selection period immediately after their joining date Members are covered under the policy from their joining date regardless of whether they are actively at work or not. Actively at work requirements are waived. A completed and signed actively at work declaration form does not need to be provided. Policy benefit increased during a benefit selection period immediately after their joining date In order to be covered under the policy for the increased policy benefit from the day the increased benefit is effective following a benefit selection period, members must be actively at work on the day they choose to increase their policy benefit. For any members who are not actively at work on the day they choose to increase their policy benefit, they will be covered in respect of the increased policy benefit when they have returned to work and are actively at work for at least 1 working day. The increased policy benefit will not be provided any earlier than the day the increased benefit is effective following the end of a benefit selection period. Member joins the pension scheme between 12 and 24 months after their first opportunity to do so and their policy benefit is less than 250,000 Members are treated as discretionary entrants and cover is subject to satisfactory evidence of health. A completed and signed actively at work declaration form does not need to be provided. In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who not actively at work on their joining date, they will be covered when they have returned to work and are actively at work for at least 5 consecutive working days. In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who are not actively at work on their joining date, they will be covered when they have returned to work and are actively at work for at least 1 working day. Policy benefit reduced or not increased during a benefit selection period immediately after their joining date In order to be covered under the policy from their joining date, members must be actively at work on their joining date. For any members who are not actively at work on their joining date, they will be covered when they have returned to work and are actively at work for at least 1 working day. A completed and signed actively at work declaration form does not need to be provided. Policy benefit increased during a benefit selection period immediately after their joining date In order to be covered under the policy for the increased policy benefit from the day the increased benefit is effective following a benefit selection period, members must be actively at work on the day they choose to increase their policy benefit. For any members who are not actively at work on the day they choose to increase their policy benefit, they will be covered in respect of the increased policy benefit when they have returned to work and are actively at work for at least 1 working day. The increased policy benefit will not be provided any earlier than the day the increased benefit is effective following the end of a benefit selection period. A completed and signed actively at work declaration form does not need to be provided. 19

Scenario Member joins the pension scheme between 12 and 24 months after their first opportunity to do so and their policy benefit is 250,000 or more Member joins the pension scheme more than 24 months after their first opportunity to do so Actively at work requirement Member is treated as a discretionary entrant and cover is subject to satisfactory evidence of health. Member is treated as a discretionary entrant and cover is subject to satisfactory evidence of health. 2.2.4 Actively at work requirements for members joining the scheme outside of the eligibility criteria but are not joining as a result of automatic enrolment ( discretionary entrants ) Scenario / policy size Fewer than 20 members Between 20 and 49 members 50 or more members without Flexible Benefits 250 or more members with Flexible Benefits Member requiring cover before they are eligible to do so ( early entrant ) Where eligibility is not linked to pension scheme membership and the member requires cover after they were first eligible to do so Member is treated as a discretionary entrant and cover is subject to satisfactory evidence of health. Member is treated as a discretionary entrant and cover is subject to satisfactory evidence of health. 20